U.S.-based charities operating abroad need screening tools to check against OFAC lists.
The risk of violating sanctions can be significant. Terrorist groups and their supporters continue to take advantage of charities to exploit charitable funds and operations to support their activities.
There are too many examples of charities that have been integral components of terrorist networks. Examples include: the Revival of the Islamic Heritage Society (RIHS), which was designated for providing financial and material support to the al-Qaeda network; the Union of Good, which was designated for providing support to Hamas; the Martyrs Foundation, which was designated for providing support to Hezbollah; Pakistan-based Jammat ud Dawa (JUD), which was designated for providing support to Lashkar E Tayyiba (LT), which itself was designated by the Department of State; and the list goes on. As of May 2010, 547 individuals and entities were designated under E.O. 13224. Of these, there are approximately 60 designated charities.
OFAC recognizes the risk of terrorist exploitation of charities, and has a number of specific recommendations to mitigate against that risk.
Check the OFAC SDN List to make sure that the charity and its key officials are not designated.
Check against various lists, and conduct a risk-assessment of operations to determine vulnerabilities.
Adopt measures to mitigate the risks of terrorist exploitation. Anti-terrorist financing procedures should include:
Collect basic information about recipients of funding;
- Conduct basic vetting of recipient organizations, including checking their names against OFAC's List of Specially Designated Nationals and Blocked Persons (the SDN List);
- Conduct basic vetting of key employees, including checking their names against the SDN List;
- Review the financial and programmatic operations of the foreign recipient organization (e.g, periodic reports, on-site visits, etc.)
"When charitable organizations use charity and humanitarian assistance to provide support for a terrorist organization or as cover to fund terrorist activity and harm innocent civilians, often in poor and impoverished regions, we have a responsibility to do all we can to shut down the funding channels of terrorism."
- Stuart Levey, Treasury Under Secretary for Terrorism and Financial Intelligence (TFI)